COMMENTARY |
Protecting Research Participants
Boston Medical Center
Boston, MA 02118
Abbreviations: IRB, institutional review board IOM, Institute of Medicine
The protection of human subjects in the United States is undergoing dramatic revision. Changes are occurring because of numerous controversies and concerns that have arisen over the last decade, including the inadequacies of institutional review boards (IRBs), 1,2 the debate over research conducted in the developing world, 3,4 violations of confidentiality in health services research, 5 changing concepts of informed consent,6,7 and the growth of the clinical research endeavor.8
In this issue of Pediatrics, Weil and colleagues9 summarize the protection of human subjects in research reports published in 3 pediatric journals in 2000. Of 379 studies they reviewed, they found that 52% documented IRB approval, 42% documented informed consent, and only 35% properly documented both IRB review and informed consent. Their results are consistent with a number of other reviews, including our own, which suggest that a substantial proportion of research reports do not contain adequate information about the protection of human subjects.1015 They also found that the rate of reported IRB approval and informed consent varied by study design. This too is consistent with our work.11 We found that 97% of randomized, clinical trials reported IRB approval, whereas only 70% of prospective cohorts, 37% of retrospective cohorts, and 9% of large dataset analyses reported approval. This suggests there is confusion about which types of studies need approval.
What role should individual investigators play in protecting human subjects? First, researchers must recognize their fundamental responsibility to those they are studying. Human subject protection is an obligation essential to the research endeavor. The primary mechanism ensuring appropriate protection of patients is review by an IRB. Although dealing with IRBs can be a tedious and time-consuming exercise, if a project involves human subjects, then investigators should seek approval from IRBs.
Second, clinicians and administrators should refrain from making the determination that a project is not research; that is the job of IRBs. Two areas of research that are particularly subject to confusion include quality improvement projects and health services. Casarett and colleagues16 suggest 2 criteria that can be used to determine whether a quality improvement initiative should be considered research and needs IRB approval. If either the majority of patients are not expected to benefit directly from the project or additional risks or burdens are imposed by the initiative, then the project should be considered research. The Institute of Medicine (IOM)5 describes quality improvement as research if the study explores unknown phenomena, collects data not routinely collected, compares alternative treatments, interventions, or processes, or manipulates current process. In general, the IOM suggests that if the intent or possible intent of the investigator is publication, then the project represents research and IRB approval is necessary.5
Even health services research, which often involves large databases that are relatively anonymous and include thousands of patients, requires IRB review. Although it generally poses no physical risks to patients, the IOM5 recently noted that health services research can violate both privacy and confidentiality. Privacy has been defined as the "the right to be left alone"17 and confidentiality refers to "controlling access to the information that an individual has already disclosed, for example, a patient to a treating physician or to an insurance company paying for care."5 It implies that further disclosure of information will not be allowed to occur without authorization. If patients do not trust that their confidentiality will be protected, then they may not seek care when appropriate, or disclose important information to health care providers. The IOM recommends that investigators should have all health services research reviewed by an appropriate review board regardless of the source of support or whether the research is subject to federal regulations.
Third, researchers should actively monitor progress in the field of human subjects protection by attending seminars and reading publications on research ethics in their field of inquiry. Attending seminars and receiving certified approval to conduct research is increasingly being monitored and mandated by many IRBs and institutions.
These basic steps for researchers complement the key role of IRBs in human subject protection. Review boards not only approve projects, but they also monitor ongoing research to assure that all applicable safeguards are followed. Unfortunately, in several recent cases, IRBs have been faulted for not applying independent judgment to research projects.18,19 IRB reform must address the potential for conflicts of interest, the need for an active patient voice, and sufficient funding to assure the expertise and care needed for a thorough review.1,2 IRBs can redesign applications and report forms for health services research to better assess risks to confidentiality and to assist investigators in complying with human subject requirements. An extensive list of recommendations for reform was recently proposed by the National Bioethics Advisory Committee (Table 1).20
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The role that peer-reviewed publications play in protecting human subjects has evolved over the past few decades. Currently, >500 journals have adopted the Uniform Requirements of the International Committee of Medical Journal editors, which stipulates that authors should describe IRB approval.21 Despite journals acceptance of the International Committee of Medical Journal editors requirements, Amdur and Biddle22 found in their review of 102 research journals, that the majority made no mention of the necessity of obtaining and disclosing IRB approval or informed consent to the journal.
The importance of distinguishing between IRB approval and informed consent is highlighted by a recent controversy in the British Medical Journal23 that published the results of 2 randomized, clinical trials24,25 in which ethics committee approval was obtained, but the participants did not give written-informed consent. Numerous letters to the editor disagreed with the publication of these reports.26,27 If the articles had simply contained statements regarding ethics committee approval, readers would have never known that informed consent had not been obtained.
I believe that peer-reviewed journals should become more aggressive in requiring statements regarding IRB approval for every research report. Just as structured abstracts have helped improve the quality of scientific reports, I believe that structured reporting of IRB approval would further the protection of human subjects. Key elements should included the following: if the IRB board determined whether the research was exempt and reason why; the type of approval obtained (full board, or expedited review); and if consent is necessary, the type of consent obtained (written or oral). Just as every research report includes a list of authors, every study should include information about the protection of human subjects. Peer-reviewed journals can play a greater role in oversight, particularly since publication is the final step for most research projects.
We applaud the report by Weil and colleagues. Their study highlights ongoing and persistent concerns about the protection of human subjects. We must not forget that vigorous protection of subjects rights is absolutely essential to public confidence in scientific progress. It is our privilege to conduct research, not our right.
| ACKNOWLEDGMENTS |
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I would like to acknowledge the many thoughtful conversations and comments of Josh Sharfstein, MD, and the helpful critiques by Robin Weinick, PhD, Peter Gergen, MD, and Joel Alpert, MD.
| FOOTNOTES |
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Received for publication Apr 12, 2002; Accepted Apr 12, 2002.
Address correspondence to Howard Bauchner, MD, Boston Medical Center, Maternity 4th Floor, 91 East Concord St, Boston, MA 02118. E-mail: howard.bauchner{at}bmc.gov
The views expressed in this article are those of the author and do not necessarily represent those of the Agency for Health care Research and Quality, or the US Department of Health and Human Services.
| REFERENCES |
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- US General Accounting Office. Scientific Research: Continued Vigilance Critical to Protecting Human Subjects. Washington, DC: US General Accounting Office; March 1996. Publication GAO/HEHS-96-72
- Office of Inspector General. Institutional Review Boards: A Time for Reform. Washington, DC: Office of the Inspector General, Department of Health and Human Services; 1998. Publication OEI-01-97-00193
- Angell M. Investigators responsibilities for human subjects in developing countries.
N Engl J Med.2000; 342
:967
969
[Free Full Text] - Lurie P, Wolfe SM. Unethical trials of interventions to reduce perinatal transmission of the human immunodeficiency virus in developing countries.
N Engl J Med.1997; 337
:853
856
[Free Full Text] - Institute of Medicine. Protecting Data Privacy in Health Services Research. Washington, DC: National Academy Press; 2000
- Hewlett S. Consent to clinical research: adequately voluntary or substantially influenced? J Med Ethics.1996; 32 :321 325
- Kruzewski MG. Reconceiving the family: the process of consent in medical decisonmaking. Hastings Cent Rep.1996; 22 :232 237
- NIH Extramural Data and Trends. Available at: http://grants.nih.gov/grants
- Weil E, Nelson RM, Ross LF. Are research ethics standards satisfied in pediatric journal publications?
Pediatrics.2002; 110
:364
370
[Abstract/Free Full Text] - Rennie D, Yank V. Disclosure to the reader of institutional review board approval and informed consent.
JAMA.1997; 277
:922
923
[Abstract/Free Full Text] - Bauchner H, Sharfstein J. Failure to report ethical approval in child health research: review of published papers. BMJ.2001; 323 :319 319[CrossRef]
- Olde Rikker MGM, ten Have HAMJ, Hoefnagels WHL. Informed consent in biomedical studies on aging: survey of four journals.
BMJ.1996; 313
:1117
1118
[Free Full Text] - Matot I, Pizov R, Sprung C. Evaluation of institutional review board review and informed consent in publications of human research in critical care medicine. Crit Care Med.1998; 269 :1596 1602
- Olson CM, Jobe KA. Reporting approval by research ethics committees and subjects consent in human resuscitation research. Resuscitation.1996; 31 :255 26[CrossRef][Web of Science][Medline]
- Ruiz-Canel M, Gomez-Gracia E, Fernandez-Crehuet J. Informed consent and approval by institutional review boards in published reports on clinical trials.
N Engl J Med.1999; 340
:1114
1115
[Free Full Text] - Casarett DC, Karlawish JHT, Sugarman J. Determining when quality improvement initiatives should be considered research.
JAMA.2000; 283
:2275
2280
[Abstract/Free Full Text] - Olmstead v U. S., 1928
- Steinbrook R. Protecting research subjectsthe crisis at Johns Hopkins. N Engl J Med.2002; 246 :716 720
- Moreno J, Caplan A, Wolpe PR, and members of the project on informed consent, human research ethics group. Updating protections for human subjects involved in research.
JAMA.1998; 280
:1951
1958
[Abstract/Free Full Text] - National Bioethics Advisory Commission. Report and Recommendations of the National Bioethics Advisory Commission. Ethical and Policy Issues in Research Involving Human Subjects. Bethesda, MD: National Bioethics Advisory Commission; August, 2001
- International Committee of Medical Journal Editors. Uniform requirements for manuscripts submitted to biomedical journals.
JAMA.1997; 277
:927
934
[Abstract/Free Full Text] - Amdur RJ, Biddle C. Institutional review board approval and publication of human research results.
JAMA.1997; 277
:909
914
[Abstract/Free Full Text] - Smith R. Informed consent: the intricacies.
BMJ.1997; 314
:1059
[Free Full Text] - Dennis M, ORourke S, Slattery J, Staniforth T, Warlow C. Evaluation of a stroke family care worker: results of a randomised controlled trial.
BMJ.1997; 314
:1071
1076
[Abstract/Free Full Text] - Bhagwanjee S, Muckart D, Jenna PM, Moodley P. HIV status does not influence outcomes of patients admitted to a surgical intensive care unit.
BMJ.1997; 314
:1077
1081
[Free Full Text] - Doyal L. Journals should not publish research to which patients have not given fully informed consentwith three exemptions.
BMJ.1997; 314
:1107
1111
[Abstract/Free Full Text] - Tobias JS. BMJs present policy (sometimes approving researching in which patients have not given fully informed consent) is wholly correct.
BMJ.1997; 314
:1111
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PEDIATRICS (ISSN 1098-4275). ©2002 by the American Academy of Pediatrics
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